OSHA has continued its proactive approach to targeting and inspecting businesses in 2013. It’s not like it used to be, when you could expect to be clear of an OSHA inspection if you kept your employees happy (i.e., no complaints to OSHA) and safe (i.e., no reportable accidents). If you met those two goals not long ago, then you were likely in the clear to avoid OSHA inspections in any given year.
That is no longer the case. As many of you may be aware, OSHA has implemented a Site-Specific Targeting Program designed to target the most dangerous employers, as measured by their DART (“days away [from work], restricted, or transferred) rate. Under the program, employers with a DART rate higher than their industry’s average are on the list for greater likelihood of inspection. This enforcement program is a marked change from OSHA’s historical approach of primarily investigating actual incidents and/or complaints.
So, did you make the list?? You would know if you did—according to the Bureau of National Affairs, OSHA mailed 9,414 letters this year to employers who did, down from about 14,950 letters in 2012 and about 14,640 in 2011.
If you made the list, your first step is to understand why you are on it—in particular, to ensure that the information that OSHA utilized accurate. Even more, you should make sure that the information you gave to OSHA (in the form of your OSHA 300 logs) is accurate and is the type of information required to be on the report. Sometimes, the fix is that easy. If not, then a more detailed dive into your safety program and work environment is needed so that you are ready for the likely inspection, and so that you can get off the list!